Emissions regulations: Compliance the hard way, by the book, etc.

In “Cleaning the Valley air requires teamwork,” a commentary authored by Casey Diaz in his touting the virtues of teamwork and how important this is in terms of realizing marked improvement of San Joaquin Valley air condition as I understand it, wrote: “Two bills in the California Legislature recognize this long-term task and the need for all of us to help each other succeed. These bills, Assembly Bill 8 by Assembly Members Henry Perea, D-Fresno, and a companion measure, Senate Bill 11, would extend incentive and funding programs that help companies like ours help clean the skies above our valley and our state.

“These bills reflect the reality that cleaner air won’t come overnight. They extend the funding programs through 2023, giving all of us a chance to make meaningful progress. And, they reflect the understanding that regulations by themselves won’t clean the skies. If we are to achieve our goals, we have to have businesses that can succeed and shoulder the burden.”

He got that right, especially the bit about “regulations by themselves won’t clean the skies.”

Not stated specifically, but implied perhaps, is that compliance of said regulations through either voluntary means or enforcement must be absolute.

Volunteering to comply, of course, would be ideal. Enforcement, on the other hand, assures regulatory compliance. But to be really effective, enforcement has to be comprehensive or thorough, in other words. Enforcement on a piecemeal basis, although that approach in and of itself is somewhat helpful, this method still comes up short, in my opinion.

Or, what about the idea of so-called “self-policing” or the policing of oneself? Come again?

“The subsidiary, Vintage Production California LLC, identified and disclosed the violations on its own, according to a news release Monday from the U.S. Environmental Protection Agency.”

Meanwhile, the EPA in the release in question titled: “Company Self-Discloses Air Violations” dated Dec. 10, 2012 pointed out: “The violations were identified and self-disclosed by Vintage, and occurred in late 2011, when the company constructed three steam generators at the oil field without first obtaining a permit for greenhouse gas emissions under the Prevention of Significant Deterioration (PSD) permitting program,” elaborating further that “PSD is a preconstruction permitting program that applies to large stationary sources of air pollution. Before beginning construction of a project that is subject to PSD requirements, the owner or operator of the facility must obtain a permit that specifies how the facility will use the Best Available Control Technology to reduce air emissions.”

Incidentally, this is the first time I had ever heard of a case such as this.

Mentioned in The Bakersfield Californian article in question was the point said company is to acquire the appropriate permit.